Since 1995, Stephen Kirkland has provided analyses, reports and expert testimony on reasonable compensation for business owners, executives, professionals, trustees and directors.  Their employers included professional service firms, closely-held businesses, hospitals and other tax-exempt organizations across the United States.


 Stephen Kirkland's 2018 and 2017 Presentations

Reasonable Compensation Job Aid for IRS Valuation Professionals

The Reasonable Compensation issue usually involves a determination of whether the amount of compensation paid is reasonable so that it is deductible under section 162 of the Internal Revenue Code for income tax purposes. In some cases, the Reasonable Compensation issue comes up when the amount of compensation paid may be lower than reasonable to avoid the payment of employment taxes.1 For tax-exempt entities, the issue involves the application of section 4958, taxes on excess benefit transactions, and reflects a concern that excessively high compensation may unduly enrich officers, directors, trustees or key employees of the tax-exempt entity at the expense of the qualified charitable purpose....




  • Planning
    Helping companies and non-profits determine reasonable and fair market value pay levels for executives and other key employees.
  • Expert Testimony
    Providing expert witness testimony in U.S. Tax Court and other court cases.
  • Opinion Letters
    Providing comparability data and opinion letters for hospital executives, physicians, non-profit managers, directors, business owners, and other executives.
  • Specialized Services
    Stephen Kirkland helps businesses and non-profits prepare for IRS audits and appeals conferences involving compensation issues.  He also helps determine: guaranty fees for those who personally guarantee corporate debts and/or leases,…

Challenges to "reasonable" compensation are among the most common, and most complex, issues raised in IRS audits of closely-held businesses and tax-exempt organizations.  Similar issues arise in shareholder disputes and business valuations.

Prepare Passionately : Analyze Thoroughly : Write Accurately : Speak Clearly : Illustrate Powerfully


An opinion may have great value if it is supported and can be defended.

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Columbia, SC 29201-3266
Telephone: (803) 724-1414